Sprietsma v. Mercury Marine

Background

A woman died after falling from an 18-foot ski boat and being struck by the boat’s propeller. Her husband sued the motor manufacturer, Mercury Marine (a division of Brunswick), in Illinois state court, saying the motor was unreasonably dangerous because it lacked a propeller guard. Lower Illinois courts dismissed the case on the ground that the federal Boat Safety Act preempted the state-law claims, and the State Supreme Court affirmed on implied preemption grounds.

Reasoning

The Court addressed whether the 1971 Federal Boat Safety Act or the Coast Guard’s later decision not to require propeller guards prevents state damage lawsuits. The justices found the Act’s express preemption language applies to state statutes and regulations, not judge-made state tort law, and noted a saving clause that preserves common-law liability. The Court also held that the Coast Guard’s decision not to adopt a propeller-guard rule does not amount to an authoritative federal policy barring state lawsuits. Finally, the Court rejected the idea that the federal scheme so fully occupies the field that it implicitly preempts all state damage claims.

Real world impact

The ruling lets state wrongful-death and product-liability claims against boat and motor makers proceed in state courts. The decision does not decide whether any particular claim will win on its facts; it only allows the lawsuits to be tried. The Coast Guard still may adopt future regulations, and state rules or jury findings could differ by place, but state damage remedies remain available.